Privacy Policy

Last Updated: June 23, 2022

BLSH (“BLSH”, “us”, “we”, “our”) has created this Privacy Policy (“Policy”) to demonstrate our

firm commitment to privacy. Due to the sensitive nature of the information we collect from our

users, including name, address and phone numbers, we believe it is important to satisfy strict

privacy requirements.

Overview

BLSH is committed to maintaining the privacy and confidentiality of our customers’ personal

information (“you”, “your”). In the course of offering and providing our services, we collect and

maintain certain personal information about you. This information can come from information

you provide on applications or other forms, through your inquiries by mail, e-mail, or telephone,

or by other means. This policy explains what personal information we collect and how we use

and share such personal information. It also explains what you can do to limit the use and

sharing of your personal information. We do not disclose personal information about our

customers to non-affiliated third parties, except as described below.

Online Privacy

BLSH may periodically collect information from you through automated means. When you

browse our site, use our services, or read our emails or newsletters, we may use “cookies” or

other online tracking mechanisms (including pixel tags, web beacons, clear GIFs and device

fingerprints) in order to provide better service, facilitate your use of the site or services, store

online preferences, track usage of the site or services, tailor the marking of business services,

or enhance security. BLSH does not store your login credentials.

Some of our cookies are used for web analytics and intelligence about our site. We may also

use web beacons or other technologies for similar purposes and we may include these in

marketing email messages or our newsletters in order to determine whether messages have

been opened and links clicked on. Web beacons do not place information on your device but

may work in conjunction with cookies to monitor online activity.

By using our site or applications you agree that we can place cookies on your device and use

other online tracking mechanisms as explained in this privacy notice. You may be able to control

your acceptance of cookies and similar technologies on a website, and most devices and

browsers offer their own privacy settings for cookies. You will need to manage your cookie

settings for each device and browser you use. If you do not accept cookies, you may experience

some inconvenience in your use of some sites and online products. For example, a website may

not be able to recognize your device and you may need to answer challenge questions or

provide additional information each time you log on.

To help us protect against fraud, provide our services to you, and improve our services, we may

collect location data and your IP addresses that are used in conjunction with our services.

We also may obtain information on the device you use, including the Universally Unique

Identifier, advertising identifier (“IDFA” or “AdID”), operating system and version, wireless

carrier, and network type. This information is used to identify customer device issues and for

marketing purposes.

If you subscribe to any of our communications, we will use your name and email address to

send communications to you. You can unsubscribe at any time following the instructions at the

bottom of these emails or you can contact us at the information below. We also may collect

information from you derived or resulting from voluntary surveys.

Information You Provide

BLSH will only collect your email address in order to create an account to use our Services, but

we will also collect additional personal information, including your name, phone number, broker

account number, and trade-related data pursuant to your use of the Services.

In addition to data you expressly provide to us, we may also utilize Google Analytics or other

analytics tools to collect information related to the pages of our website that you visit, how long

you stay on a particular page, and how you use our Services. Any analytics data we collect will

not contain any of your personally identifiable information and will be strictly limited to our own

internal use.

Protecting information

With regard to our internal security procedures, we restrict access to your personal and account

information to those employees who “need to know” the information in order to provide products

and services to you. We maintain reasonable physical, administrative, and technical safeguards

to protect your personal information. We conduct regular internal audits of our business

practices and procedures in order to protect your personal information.

We may also disclose your personal information as required by law, such as to comply with a

subpoena, or similar legal process and when we believe in good faith that disclosure is

necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or

respond to a government request.

We are not responsible for inaccuracies in data provided by third parties, such as credit

reporting bureaus. You may review and correct your data by contacting us at info@BLSH.live.

Retention of Your Information

We will retain your personal information for as long as it serves the purposes(s) for which it was

initially collected as stated in this Privacy Policy, or subsequently authorized. We will also retain

and use personal information as necessary to comply with our legal obligations, resolve

disputes, or enforce our agreements. If you are no longer a customer, we will not destroy your

information unless required or permitted by law. We will continue to treat your personal

information in accordance with this privacy policy and applicable laws.

Information connected to you that is no longer necessary and relevant to provide our services

may be aggregated with other non-personal data to provide insights which are commercially

valuable to BLSH, such as statistics of the use of BLSH Services.

Children’s Privacy

We do not knowingly collect or solicit any information from anyone under the age of 18 on our

services. In the event that we learn that we have inadvertently collected personal information

from a child under age 18, we will take reasonable steps to delete this information. If you believe

that we might have any information from a child under 18, please contact us at info@BLSH.live.

California Privacy Rights

If you are a California resident, California law requires us to provide you with some additional

information regarding how we collect, use and share your “personal information” (as defined in

the California Consumer Privacy Act (“CCPA”)), other than the personal information we collect

in connection with providing financial products and services.

Depending on how you interact with our website and services, we may collect the following

categories of personal information about you, in addition to the information we collect in

connection with providing financial information and services:

Identifiers, such as your name and contact information (if provided), IP address, and device

identifiers.

Internet usage information, such as browsing history, access history, and use and interaction

with our website.

This information is used and disclosed for the purposes and to the categories of third parties

described in the main privacy policy, above.

Your California Privacy Rights: If you are a California resident, you may have certain rights.

California law may permit you to request that we:

● Provide you the categories of personal information we have collected or disclosed about

you in the last twelve months; the categories of sources of such information; the

business or commercial purpose for collecting or distributing your personal information;

and the categories of third parties with whom we shared personal information.

● Provide access to and/or a copy of certain information we hold about you.

● Delete certain information we may have about you.

We do not sell your personal information to third parties. We do allow third parties to collect

personal information through our service and share personal information with third parties for

the business purposes described in this Privacy Policy, including without limitation advertising

and marketing on our service and elsewhere based on users’ online activities over time and

across different sites, services, and devices.

California law permits consumers to request, once per year, that we disclose the identity of any

third parties with whom we have shared personal information for the third parties’ direct

marketing purposes within the previous calendar year, along with the type of personal

information disclosed. Please contact info@BLSH.live for such requests.

Updates to this Policy

As required by federal law, we will notify you of our privacy policy annually. We reserve the right

to modify this policy at any time. If we do change it, we will revise the “Effective Date” above and

post the new policy. To stay informed of our privacy practices, we recommend you review this

Policy on a regular basis as you continue to use our Services.

Opt-Out

BLSH provides users the opportunity to opt-out of receiving communications from us at the point

where we request information about you. You can send an email to info@BLSH.live and request

that we remove your information from our database, to not receive future communications, or to

no longer receive our Services.

Other important information

State and International Laws

For Vermont Residents: In accordance with Vermont Laws, we will not share information we

collect about Vermont residents with companies who are not affiliates, except as permitted by

law, such as with your consent or to service your accounts. We will not share information about

your creditworthiness with our affiliates without your authorization or consent, but we may share

information about our transactions or experiences with you with our affiliates without your

consent.

For Nevada Residents: Nevada law requires us to disclose that you may request to be placed

on BLSH’s internal “do not call” list at any time by emailing us at info@BLSH.live, and that we

are providing this notice to you pursuant to state law, and that you may obtain further

information by contacting the Nevada Attorney General, 555 E. Washington Ave., Suite 3900,

Las Vegas, NV 89101; phone 702-486-3132; email BCPINFO@ag.state.nv.us.

For California Residents: In accordance with California law, we will not share information we

collect about you with nonaffiliates, except as allowed by law. For example, we may share

information with your consent or to service your accounts. Among our affiliates, we will limit

information sharing to the extent required by California law.

For questions about our policy, or for additional copies of this notice, please email us at

info@BLSH.live.